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Gary Scannavino • -2 - 10 June 2004 <br /> wastewater generated at the trailer washing facility to the wastewater applied to land. If the values are <br /> more than six-percent different, CFL must explain the variance and ensure that all wastewater is <br /> discharged consistent with the WDRs. <br /> Revised Monitoring and Reporting Program <br /> Staff has determined the Monitoring and Reporting Program should be revised to better characterize <br /> wastewater quality at the site and make the MRP consistent with other industrial wastewater generators. <br /> By 10 July 2004 please provide comments on the enclosed Draft MRP. Upon finalization, the <br /> Executive Officer will sign the Revised MRP and it will become active. <br /> Groundwater Monitoring <br /> Groundwater monitoring is required to determine if the wastewater discharge is degrading groundwater <br /> quality. Therefore by 30 July 2004 CFL is required to submit a groundwater monitoring well <br /> installation workplan. The workplan must be prepared under the supervision of a California licensed <br /> engineer or geologist and shall be consistent with the attached guidance document Requirements for <br /> Monitoring Well Installation Workplan and Monitoring Well Installation Reports. The workplan must <br /> include a schedule for well installation and all installation work shall be completed by 30 September <br /> 2004. Groundwater monitoring shall begin no later than the Fourth Quarter 2004. <br /> Other Issues Discussed at the Facility <br /> Staff observed hoses and erosion patterns that indicated wastewater or stormwater that lands on the <br /> wastewater treatment equipment is discharged to the stormwater pond. Such a discharge is prohibited by <br /> Discharge Specification B.4 of the WDRs. The draft revised MRP includes monitoring of the <br /> stormwater pond to determine the extent of such discharges. If wastewater is discharged to the <br /> stormwater pond, additional monitoring, including groundwater monitoring, will be required at that pond <br /> and the pond will have to comply with the Regional Boards storage criteria for wastewater ponds. This <br /> issue will be further evaluated after adequate monitoring is performed. <br /> CFL has not installed a Reverse Osmosis (RO) system to replace the water softening ion exchange <br /> system historically used despite the 2001 Annual Land Management Report that described the <br /> replacement plan. The Regional Board is not requiring installation of an RO system but pending better <br /> characterization of the quality and quantity of the CFL wastewater, salinity reduction programs may be <br /> required. <br /> If you have any questions on this Notice of Violation, draft Revised MRP, groundwater monitoring <br /> requirement or other issues related to the facility,please telephone Tim O'Brien at (916) 464-4616. <br /> WENDY WYELS, Chief <br /> Waste Discharge to Land Unit <br /> enc. Summary Inspection Report <br /> Draft Revised Monitoring and Reporting Program No. 98-077 <br /> Requirements for Monitoring Well Installation Workplans and Well Installation Reports <br /> cc w/enc: Mike Huggins, San Joaquin County Environmental Health Department, Stockton <br /> David Irey, San Joaquin County District Attorney's Office, Stockton <br /> W:VSu9106nm116m Jmgou`SLvota FrieLi�Snou I J..K rc <br />